alllopucki.law.ucla.edu/RoutineIllegalityDocuments/Appendix 2 Prior... · • Confer with the...

• Review and analyze SEC forms, materials and rules regarding reorganizations inorder to ensure compliance.

• Draft and revise the Form T-3 ("T-3"), required by the SEC which containsinformation regarding the terms of all indenture

• Draft amendments to the T-3.

• Internally confer regarding various issues, such as the T-3 and amendmentsthereto, the distribution of securities, the Committee on Uniform SecuritiesIdentification Procedures number, the election form, the reincorporation of theDebtors, and the merger and dissolution of affiliates of the Debtors.

• Review the listing requirements of the NASDAQ.

• Draft the election form for the new securities.

• Draft the notice of extension of the date by which elections must be made.

• Confer with Innisfree M&A Incorporated ("Innisfree"), the Debtors' solicitationand tabulation agent, regarding the election form.

• Review the closing checklist.

• Review, negotiate and comment upon the Transfer Agent Agreement.

• Participate in internal conferences of the Corporate and Tax departments

• Draft press release regarding the allocation of New Notes.

• Review the Plan regarding the cancellation of certain securities.

• Conduct research in connection with Italian securities issues and the implicationsof an election of New Notes for Italian holders of securities.

• Respond to numerous creditor questions regarding corporate and securities issues.

• Review and confer internally regarding the Corporate Monitors' report entitled"Restoring Trust: Corporate Governance for the Future of MCI" (the "BreedenReport") to ensure compliance with the recommendations set forth therein.

HOI :\297666\01 \60_$01 !.DOC\81793.0004 30

I. Asset Dispositions (Work Code 300)

Total hours:Total fees:

2,036.4$886,347.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Lori Fife, Adam Cohen, Sharon Youdelman, Stuart Hirsch,Michael Skarda, Lydia Protopappas, Jessica Fink, Cinthia Trajtenberg and Jared Friedman.Their time represents 79% of the time billed to this work code.

• Advise the Debtors regarding assets to be disposed of pursuant to the orderauthorizing the Debtors to sell certain property and interests in property free andclear of all liens, claims and encumbrances and establishing the procedurestherefor and authorizing the Debtors to abandon or donate certain personalproperty and establishing procedures therefor.

• In connection with the disposition of Embratel, WG&M expended a tremendousamount of hours on the following tasks:

• Confer with the Debtors' Brazilian counsel in order to understand andanalyze Brazilian law and various telecommunications regulatoryagencies;

• Confer with the Debtors, Lazard and Brazilian counsel regarding the duediligence process;

• Negotiate the terms of the non-disclosure agreement entered into bypotential purchasers and bidders;

• Draft and revise the non-disclosure agreement in connection with thedataroom discovery process;

• Coordinate and assemble production dataroom of diligence documents;

• Review documents to be produced to bidders as part of the due diligenceprocess in connection with the Embratel sale;

• Draft and revise stock purchase agreement in connection with the sale ofthe controlling interest in Embratel;

• Draft schedules to the stock purchase agreement;

• Draft motion for an order pursuant to Sections 363 and 1146 of theBankruptcy Code and Bankruptcy Rule 6004 approving the terms andconditions of a stock purchase agreement with Telefonos de Mexico, S.A.de C.V., and authorizing the sale of Embratel;

HOI :\297666\01\6D_$01LDOC\8 I793,0004 31

• Research and draft memorandum concerning the standing of adisappointed bidder in connection with an asset sale pursuant to Section363 of the Bankrupcy Code.

.. Research evidentiary rules in preparation for the hearing to approve theEmbratel sale;

• Coordinate and supervise the translation of Portuguese documents,including the business records of Embratel;

• Internally confer among WG&M's Corporate, Litigation and BFRdepartments to coordinate efforts and strategize;

• Interview potential witnesses for the hearing to approve the Embratel sale;

• Prepare witnesses to testify at the hearing, including prepare witnessoutlines;

• Prepare hearing exhibits;

• Draft opening and closing statements;

• Develop hearing strategy;

• Attend to issues in relation to the sale of Multichannel Multipoint DistributionService ("MMDS"), the Debtors' fixed wireless broadband business, such as:

• Draft and revise the stipulation between the Archdiocese of Los AngelesEducation, the Welfare Corporation and the Debtors;

• Review the MMDS closing checklist.

• Draft motion for an order, pursuant to sections 105 and 363 of the BankruptcyCode, approving the sale of the Debtors' Claim in the Light year Holding, Inc., etal. bankruptcy cases.

• Prepare and draft the Debtors' fourth report of de minimis asset sales andabandonments of personal property for the quarter ending September 30, 2003.

• Prepare and draft the Debtors' fifth report of de minimis asset sales andabandonments of personal property for the quarter ending March 31, 2004.

• Prepare for and attend hearing to consider the asset purchase agreement forcertain tower assets.

HOI :\297666\01\60_$01 !.OOC\81793.0004 32

m, Real Property Leases (Work Code 310)


413.9$153,679.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Stephen Youngman, Michelle Larson, Stephanie Simpson,Kristin Simpson and Christina Pullo. Their time represents 83% of the time billed to thiswork code.

• The Debtors had over 15,000 property leases with numerous entities prepetition.As such WG&M is required to assist the Debtors with the review and analysis ofthousands of leases in order to determine whether the leases are beneficial to theestates and to make determinations as to the assumption or rejection of theseleases. In conjunction therewith, WG&M assisted the Debtors with thenegotiation and drafting of agreed amendments and terminations of real propertyleases.

• In an effort to preserve the value of the Debtors' estates, draft and defend motionsto reject leases and file notices of rejection for real property over 250 leases forproperty which is no longer needed in the Debtors' ongoing business operations.

• Draft, file and defend motions to assume real property leases as amended, manyof which contained substantial rent savings or were otherwise beneficial to theestates.

• Conduct numerous teleconferences with landlords, lienholders, their counsel andother interested parties regarding lease assumptions and rejections, lease auctions,lease designations, and other lease issues.

• Participate in numerous telephone conversations and correspondence with lenders'counsel, the Debtors' in-house attorneys and surveyors in connection with variousproperties.

• Prepare notices and schedules for abandonment of various licenses.

• Review surveys-of various properties owned by the Debtors.

• In an effort to preserve the value of the Debtors' estates, draft numerous noticesof abandonment for certain real property.

• Review the purchase agreements relating to the assets of certain tower sites (the"Tower Assets").

• Draft several asset sales motions and orders relating to the sales of theTower Assets and the exhibits thereto.

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• Respond to inquiries by the Creditors' Committee and any other potentialbidders or objectors to the asset sales motions.

• Prepare for, attend and argue at the hearings to consider the asset salesmotions.

n, Executory Contracts (Work Code 320)


739.0$285,661.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Alfredo Perez, Lydia Protopapas, James Grogan, RichardGraham, Renee Wells and Christina Pullo. Their time represents 84% of the time billed tothis work code.

• To reduce the Debtors' costs and maximize the value of the Debtors' estates,review thousands of contracts, each of which require analysis of characterization,assumption and rejection options and post-petition obligations.

• Draft notices of settlement, motions for approval of settlements, settlementagreements, motions to approve contract amendments and modifications.

• Conduct research and provide counsel regarding cure of defaults and numerousissues regarding rejection of contracts and leases.

• Prepare motions, stipulations, agreed orders and Plan Supplements related toassumption, assumption and assignment, and rejection of executory contracts andunexpired leases.

• Draft memoranda analyzing the Debtors' rights and obligations under certainexecutory contracts.

• Draft and file motions and notices and prepare for and successfully conducthearings at which the Debtors were granted the authority to assume or reject morethan 2,800 executory contracts.

• Research, resolve and draft numerous objections to motions to compel assumptionor rejection of certain executory contracts.

• Draft the objection to the motion of Grande Communications Networks, Inc. forthe allowance and payment of junior superpriority administrative claim inconnection with prepetition executory contract that was amended postpetition.

• Research the application of Section 503(b)(1)(A) of the Bankruptcy Code to apostpetition agreement that is no longer beneficial to the estate.

HOI :\297666\01 \6D_$0I LDOC\81793.0004 34

• Negotiate and draft stipulations in connection with the rejection of certainexecutory contracts; negotiate settlements and settlement agreements inconnection with the rejection of certain executory contracts and draft motionsseeking approval of these settlements with various entities.

• Draft motions and stipulations regarding settlements of certain pre-petitioncontract disputes.

• Participate in regular conference calls with MCl's Settlement Task Force and theCreditors' Committee regarding terms of various pending settlements andconferences with the Debtors and contract counterparties regarding terms ofsettlements.

• Advise the Debtors and various contract counterparties regarding de minimissettlement procedures and draft notices of settlement in accordance with deminimis settlement procedures.

• Review correspondence regarding settlement agreements.

• Research issues related to settlements, including setoff, recoupment, assumptionand assignment, and adequate assurance issues.

• Draft notices of setoff in accordance with de minimis setoff procedures.

• Draft and update lists of pending and approved settlements.

• Advise the Debtors regarding Plan provisions related to assumption and rejectionof executory contracts.

• Coordinate obtaining signatures for settlement agreements and distributing ordersapproving final settlement agreements.

• Review claims database regarding claims related to executory contracts andcertain settlement agreements.

• Researched and corresponded internally and with opposing counsel about variousclaims of former MCI director for deferred compensation and discovery relatedthereto.

HOI :\297666\01 \6D_$01 !.DOC\81793.0004 35

o. Automatic Stay/Adequate Protection (Work Code 330)


794$342,183.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Adam Strochak, Lydia Protopappas, Jason Billeck, RonitBerkovich, Anthea Dinos and John Thompson. Their time represents 78% of the time billedto this work code.

• Review requests for modification of the automatic stay to allow certain actions toproceed, including state court litigation, actions for recoupment, and requests forpermission to setoff certain obligations (the "Automatic Stay Motions"),including, but not limited to motions by: Arthur Andersen LLP, TeleserveSystems, Inc., Mark Lahit, Gary Campbell, MDIP Litigation Trust, Time WarnerTelecom Holdings, Inc., Detroit Edison Company, Southern California EdisonCo., Paul Browning, Alan M. Grayson and Lexington Insurance Co.

• To maintain the integrity of the Debtors' automatic stay, analyze and advise theDebtors on the Automatic Stay Motions and resolve the Motions by eitherentering into stipulations with the movants allowing the litigation to proceed,objecting to the motion, or allowing the motion to proceed, as the factors of thespecific cases mandated.

• Settle / resolve approximately 9 motions to lift the automatic stay byagreement, consent order, withdrawal of motion, or stipulation.

• Oppose approximately 8 motions to lift the automatic stay.

• Settled one motion to setoff funds against the Debtors.

• Advocate for the denial of 16 motions to lift the automatic stay.

• Continuously oppose numerous pending Automatic Stay Motions.

• Conduct extensive research and discovery in opposing the Automatic StayMotions.

HOl:\297666\OI\6D_$OI !.DOC\81793.0004 36

p. Claims Resolution & Administration (Work Code 400)


3,051.7$1,146,698.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Alfredo Perez, Adam Strochak, Jason Billeck, Peter Friedman,Richard Graham, James Grogan, Claire Watkins, Sharon Loftspring, Eric Lyttle, DavidTaylor, Christina Pullo and Christopher Lopez. Their time represents 85% of the time billedto this work code.

• In order to decrease the number and amounts of claims against the Debtors,participate in numerous meetings and conference calls with client to develop andimplement procedures for analyzing over 38,000 claims filed, identify disputedclaims, and prosecute objections thereto.

• Respond to thousands of phone calls and letters received from creditors and otherparties in interest concerning the Debtors' chapter 11 cases, the consequence offiling claims against the Debtors, the rights of creditors under the BankruptcyCode, proofs of claim, allowance of claims, prosecution of claim objections andrelated issues.

• Draft and file the nineteenth omnibus claim objection, objecting to 75 proofs ofclaim totaling more than $25,825,662.39.

• File and prosecute objections to proofs of claims totaling over $10,280,016.73 by15 individual creditors.

• Coordinate with other law firms prosecuting various objections to claims toensure claimants with multiple claims are addressed comprehensively.

• Research and draft objections to entities filing motions to amend proof of claimsand file late claims.

• Prepare for, attend and argue at hearings regarding the above referencedmotions and objections.

• Prepare stipulations regarding allowance of certain late claims.

• Negotiate and draft various stipulations regarding disputed proof of claims.

• Draft objections and negotiate resolution of numerous applications foradministrative expense claims, including mediate settlement of an administrativeexpense claim filed by Xerox Capital Services.

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• Research the local rules in the Southern District of New York onmediation in connection with the resolution of claims against XeroxCapital Services.

• Prepare stipulations regarding allowance of claims filed by the Indenture Trustee.

• Prepare for, attend, and advocate at the hearing to consider the FourteenthOmnibus Objection to Proofs of Claims, including brief subordination issues.

• Respond to claimants' inquiries regarding treatment and distribution of claimsunder the confirmed Plan.

• Draft settlement agreements between MCI and various creditors including, but notlimited to, Cablevision Lightpath, Inc. and Verizon Communications, Inc..

• Research in connection with the Debtors' claims against AdvancedTelecommunication Network, Inc., ("ATN") and claims asserted by ATN againstthe Debtors.

• Conduct due diligence in connection with the Debtors' objection to claims basedon the substantive consolidation of the Debtors' entities.

• Research and draft memoranda and position papers regarding dischargeability andpriority of punitive damages, fines and restitution of private, state and federal(civil and criminal) claims, and court's jurisdiction over such claims.

• Research and draft memoranda on mandatory and equitable subordination ofsecurities-related ERISA claims (and related contribution claims).

• Draft and revise a release agreement between the Debtors and certain parties,most notably the MCI Trade Claims Committee, the Creditors' Committee andPlatinum Partners LP mutually releasing each party from any liability inconnection with claims filed by the respective parties.

• A team of WG&M attorneys expended a significant amount of hours to theresolution of Wells Fargo's claims in connection with the Wells Fargo Litigation,including:

• Answer in-depth discovery requests, including interrogatories;

• Review and produce numerous documents;

• Prepare witnesses for the hearing on March 22, 2004;

• Review expert testimony;

• Depose expert witness;

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• Draft pre-trial brief;

• Prepare for, attend, and represent the Debtors at the hearing;

• Conduct full-day trial;

• Draft post-trial brief.

• In connection with the claims asserted by the Abbott Litigants" againstWorldCom, Inc. alleging that WorldCom aided and abbetted and controlledWorldAccess, Inc. in committing securities fraud, it was necessary for WG&M to:

• Draft an objection to the Abbot Litigants' proof of claim for damagestotaling $622 million in connection with prepetition litigation in Californiastate court;

• Draft and file a dispositive motion ordered by the Court in response to theAbbott Litigants' motion for the Bankruptcy Court to abstain from hearingtheir claim and to allow them to proceed in the state action pending inCalifornia.

q. Adversary Proceedings (Work Code 420)


454$217,937.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Joseph Allerhand, Mark Jacoby, Adam Strochak, Pierre Davis,Caroline Lee and Ian Wilbur. Their time represents 79% of the time billed to this work code.

• In order to maintain the Debtors' estates and properties, defend the Debtors innumerous adversary proceedings filed against the Debtors, including, but notlimited to, the ERISA Litigation.

• In connection with the ERISA Litigation, it was necessary for WG&M to:

• Review over 30,000 documents produced by individually nameddefendants, including Merrill Lynch & Co., Inc. ("Merrill Lynch"), andthe Debtors in order to respond to specific privilege issues raised by theplaintiffs regarding communications between the Debtors and its ERISAcounsel, Stearns Weaver Miller Weissler Alhadeff & Sitterson, P.A.;

4 The Abbott Litigants are those parties which filed proofs of claim nos. 17111, 17112, 22573,22574,24817,24818 and 24819.

HOI :\297666\01 \60_$01 !.DOC\81793.0004 39

• Research legal issues related to attorney-client privilege, settlor andfiduciary functions, and the fiduciary exception to the privilege;

• Participate in conference calls with counsel for other parties in order todiscuss privilege issues raised by the plaintiffs prior to depositions;

• Assist in the deposition preparation of the Debtors' outside ERISA counseland individual named defendants with respect to maintaining the Debtors'attorney-client privilege;

• Draft correspondence to the plaintiffs in response to issues raisedregarding privilege issues and ongoing discovery;

• Review documents produced by Merrill Lynch and other parties in orderto ensure continued protection of the Debtors' attorney-client privilege;

• Draft privilege log for document production by Defendant Merrill Lynchto ensure continued protection of WorldCom's attorney-client privilege;

• Draft supplemental privilege log for document production by the Debtors'outside ERISA counsel and produce additional documents in response toissues raised by the plaintiffs.

• Represent the Debtors in adversary proceedings filed by the Debtors againstentities, including:

• Against Rosemarie Campos, seeking a temporary stay pursuant to section105(a) of the Bankruptcy Code of a personal injury lawsuit against certainnon-debtor parties filed by defendant Rosemarie Campos in the SupremeCourt for Kings County, New York, on August 4, 2000, which sought $5million in damages (the "Campos Proceeding");

• Against Duane G. West, seeking declaratory relief to foreclose Mr. West'sintention to seek redress for prepetition conduct even after the EffectiveDate;

• Against Advanced Telecommunication Network, Inc., ("ATN"), seeking adeclaratory judgment that (i) the Debtors are not obligated to pay anyamounts to ATN for its alleged postpetition services, (ii) to the extent anyamounts are owed to ATN for postpetition services, those amounts areowed by a third-party, and (iii) order the third-party to indemnify theDebtors as a result of ATN's claims against the Debtors;

• Against PPL Prism, LLC, seeking a declaratory judgment that the Debtorshave the exclusive beneficial ownership of, and indefeasible right of use ofa certain portion of a fiber network, and that these interests are theproperty of the Debtors' estates.

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• Successfully defend the Debtors by negotiating a stipulation and order in theCampos Litigation.

r. Non Bankruptcy Litigation (Work Code 430)


203.5$94,879.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Joseph Allerhand, Jason Billeck, PeterFriedman and David Southard. Their time represents 70% of the time billed to this workcode.

• In connection with the complaint filed by AT&T Corporation in the United StatesDistrict Court for the Eastern District of Virginia, alleging that the Debtorsengaged in improper least cost routing practices (the "AT&T Litigtation"):

• Negotiate and draft stipulation and order extending the deadline to answerthe complaint;

• Internally confer regarding motion to dismiss the AT&T Litigation;

• Research the standard for granting venue transfers in the Southern Districtof New York;

• Draft motion to transfer venue from the Eastern District of Virginia to theSouthern District of New York;

• Review, revise, and finalize the stipulation of dismissal in connection withthe AT&T Litigation.

• Attend to issues regarding the proceeding filed by pro se plaintiff FrederickStampone against the Debtors, including:

• Draft the reply in support of the Debtors' motion to dismiss due toStampone's violation of the automatic stay, which resulted in the Court'sdecision to dismiss Stampone's cause of action;

• Review Stampone's notice of appeal of the dismissal.

HOI :\297666\01 \6D_$01!.DOC\81793.ooo4 41

s. Corporate GovernancelBoard (Work Code 440)


2,655.9$1,363,444.43

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Frederick Green, Simeon Gold, Lori Fife,Holly Gregory, Bethany Cooper and William Welty. Their time represents 89% of the timebilled to this work code.

• Advise the Debtors' board of directors and senior management regardingcorporate governance matters.

• Attend meetings of the WorldCom board of directors.

• Devote substantial time to conducting research and drafting the articles ofincorporation and the by-laws of the reorganized Debtors to incorporatecompliance with governance reforms.

• Participate in numerous internal teleconferences and meetings and teleconferenceswith the Debtors' management to analyze and draft the reorganized articles ofincorporation and by-laws.

• Review the Breeden Report in conjunction with drafting the governanceprovisions of the articles of incorporation and bylaws to prepare for a conferencecall with the Corporate Monitor.

• Conduct discussions with the Corporate Monitor, the Creditors' Committee, andthe Debtors regarding corporate governance and control issues.

• Implement the recommendations contained in the Breeden Report into corporategovernance documents, such as the certificate of incorporation, the by-laws, theCommittee Charters and the Corporate Governance Guidelines.

• Analyze the recommendations in the Breeden Report, including draftingmemoranda, implementation charts, and comparisons with SOXA/listing rulecompliance.

• Draft the certificate of incorporation, the bylaws, the Corporate GovernanceGuidelines and the Committee Charters for the Audit, Compensation, Nominatingand Corporate Governance, and Risk Management Committees of theReorganized Debtors' .

• Confer with the Corporate Monitor, members of the Debtors' board ofdirectors and the Creditors' Committee regarding revisions to theaforementioned documents.

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• In order to comply with federal securities laws, specifically SOXA, draftadditional corporate governance documents, including, but not limited to, theCEO/CFO Code of Conduct, Whistleblower Policy, Disclosure CommitteeCharter, Disclosure Controls and Procedures, Insider Trading/Regulation FDPolicy.

• As part of MCl's defensive measures, draft Stockholder Rights Plan (includingterm sheets, Form 8-A, Form 8-K, press release, summary for Board and letter tostockholders).

• Present information and materials to the Debtors' board of directors regarding theproposed Stockholder Rights Plan.

• Conduct discussions with Creditors' Committee regarding the Stockholder RightsPlan.

• Review of legends to appear on Stock Certificates and coordination with theDepository Trust Company ("DTC") regarding such legends.

• Coordinate with DTC regarding the Direct Stock Registration.

• Review and provide comments to the Debtors regarding MCl's lO-K and lO-Qsprior to their filing.

• Attend to issues in connection with corporate checklists, timelines, and statuscalls throughout the Fourth Compensation Period in preparation for the Debtors'emergence from chapter 11.

• Revise T-3, the form which contains information regarding the terms of anindenture, and which is required by the SEC whenever the terms of an indentureare revised.

• Revise Form T-1 ("T-1"), the form which contains information regarding thetrustee of an indenture, and which is required by the SEC to accompany a T-3.

• Respond to SEC comments to the original T-3 and T-l.

• Review capitalization and ownership structure of all of the Debtor entities whichguaranteed indentures, pursuant to the SEC's request for more informationregarding each of the Debtors' subsidiary guarantors.

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t. Disclosure Statement (Work Code 450)


17.3$7,621.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Greg Danilow and Itiva Chopra. Their time represents 100% ofthe time billed to this work code (Please note that the attorneys billing to the DisclosureStatement work code misplaced their time, which should have been included under theCorporate Governance/Board work code).

• Conduct research in connection with the proxy statement disclosure of theReorganized Debtors.

u. GovernmentaJlRegulatory Communications (Work Code 460)


67.4$29,499.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, John Sipple and David Taylor. Their timerepresents 73% of the time billed to this work code.

• Advise and assist MCI Network Services Inc. to assign private radio licenses toNorthwest Pipeline Corporation with the approval of the FCC, which regulates theuse and assignment of private radio licenses. Specifically, the work included:

• Advise the Debtors on various issues, such as a proposed managementagreement and FCC approval to assign licenses;

• Collect information for the assignment application and ownership report;

• Assess the implications of the assignment application;

• Work with opposing counsel on filing a joint assignment application;

• Draft and revise public interest statement;

• Review new settlement agreement;

• Discuss the proposed transaction with the FCC;

• Draft and submit the assignment application;

• Assist in filing the ownership report;

• Amend the assignment application.

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v. Committee CommunicationslMeetings (Work Code 470)


61.0$37,666.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Lori Fife and Alfredo Perez. Their timerepresents 77% of the time billed to this work code.

• In an effort to reduce potential objections to various motions, work closely withthe Creditors' Committee to resolve their issues and answer questions with regardto the Debtors' motions, such as motions seeking approval of various settlementagreements, and other concerns, such as criminal actions and governmentalissues.

• Prepare for and attend meetings of the Creditors' Committee.

• Strategize with the Debtors in preparation for the Creditors' Committee meetings.

w. Avoidance Actions (Work Code 500C) and Ebbers Transaction (Work Code 505)


358.8$149,770.50

The primary billing attorneys that provided services under these work codes during theFourth Compensation Period were Marcia Goldstein, Sharon Youdelman, Scott Cohen, RonitBerkovich, Virginia Johnson and Christina Pullo. Their time represents 94% of the timebilled to these work codes.

• Review the proofs of claim filed by Bernard J. Ebbers, WorldCom's former CEO(the "Ebbers Claims").

• Review various documents related to the Ebbers Claims, including the separationagreement between WorldCom and Mr. Ebbers, dated April 29, 2002, and otherloan and guaranty agreements.

• Analyze and assess the merits of the Ebbers Claims against the Debtors.

• Conduct research and an analysis in connection with the Debtors' objections anddefenses to the Ebbers Claims.

• Confer internally regarding the Ebbers Claims.

• Draft a memorandum to MCl's board of directors assessing the merits of theEbbers Claims.

• Present the findings contained in the aforementioned memorandum to the Board.

HOI :\297666\01\6D_$01 !.DOC\81793.0004 45

x. CreditorNendor/Customer Communications (Work Code 510)


257.8$84,278.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Richard Graham, Elana Lederman, Richard Guida and ChristinaPullo. Their time represents 95% of the time billed to this work code.

• In an effort to facilitate productive relationships between the Debtors and theircreditors, advise the Debtors regarding business issues with customers, vendorsand suppliers.

• Communicate directly with numerous vendors, customers and creditors regardingeffects of the Debtors' cases under chapter 11, consequences of filing claimsagainst the Debtors, interpretation of various orders, certain settlements, thenotice regarding MCI Pre-merger Claims, dated November 19,2003, and issuessurrounding the confirmation of the Plan and distributions made in accordancewith the terms of the Plan.

y. International Issues (Work Code 520)


25.9$14,343.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Frederick Green and Scott Cohen. Their timerepresents 66% of the time billed to this work code.

• Due to the size and international nature of the Debtors' businesses, WG&M isinvolved with WorldCom's ongoing operations at the global level. Therefore, itwas necessary to prepare for and participate in weekly telephone conferences withthe Debtors' legal team in charge of the Debtors' non-debtor subsidiaries andaffiliates located in Europe, the Middle East and Asia.

• Draft motion pursuant to Sections 105 and 363 of the Bankruptcy Code forauthorization to rationalize the corporate structure of international operations inAsia-Pacific region in order to implement a realignment of the Debtors'subsidiaries located in Southeast Asia, Australia and the Pacific Rim (the "AsiaPac Group") pursuant to which ownership of the Asia-Pac Group would beconsolidated under a newly organized holding company.

HOl:\297666\OI\6D_$OI LDOC\81793.0004 46

z. Intermedia Analysis (Work Code 530)


2.1$754.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Daniel Holzman and Christina Pullo. Their time represents 76%of the time billed to this work code.

aa. Plan Confirmation (Work Code 560)


2,504.9$1,279,295.34

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Lori Fife, Stuart Goldring, Alfredo Perez,Adam Strochak, Sharon Youdelman, Lydia Protopapas, Christopher Marcus, Jessica Fink,Idit Froim, Scott Cohen, James Grogan, Ronit Berkovich and Christina Pullo. Their timerepresents 87% of the time billed to this work code.

• Intensely negotiate issues in the Plan with various parties, including the Creditors'Committee, the MatlinPatterson Group (hereinafter defined), the ad hoccommittees of Intermedia, WorldCom, and MCI bondholders, the US Departmentof Justice, and the US Trustee, in order to formulate a consensual plan ofreorganization which would likely lead to confirmation and an expeditiousemergence from chapter 11.

• Conduct meetings and teleconferences with the Creditors' Committee and theprepetition lenders regarding various plan of reorganization issues.

• Confer internally and with the Debtors and Lazard regarding plan ofreorganization issues.

• Coordinate internally between the Litigation Department and the BFRDepartment in preparation for the final day of the Confirmation Hearing.

• Review, formulate responses to, and work towards a resolution of, eightobjections to the Second Amended Plan, specifically relating to the strenuousopposition to the classification of WorldCom General Unsecured Claims, MCIPre-merger Claims, and Ad Hoc MCI Trade Claims Committee Claims togetherin one Class.

• Prepare for, attend, and represent the Debtors at the Confirmation Hearing onOctober 15,2003.

Hal :1297666\01\6D_$01 LDOC\81793.0004 47

• Negotiate and draft amendments to the Second Amended Plan to comply with theCourt's ruling to separately classify certain of the WorldCom General UnsecuredClaims.

• Expend numerous hours drafting of the proposed findings of fact and conclusionsof law (A) approving (i) substantive consolidation and (ii) the settlements underthe Debtors' Modified Second Amended Plan and (B) confirming the Debtors'Modified Second Amended Plan.

• Draft the proposed order confirming the Modified Second Amended Plan.

• Research issues related to Section 1129(b) of the Bankruptcy Code, the "cramdown" provision.

• Review and analyze the Third and Final Report of Dick Thornburgh, BankruptcyCourt Examiner, regarding the potential implications on plan confirmation issues.

• Conduct meetings and teleconferences with the Debtors, the Creditors'Committee and internally to discuss the implementation of the Plan.

• Attend to net operating loss and allocation issues.

• Address various issues in connection with the oversubscription of elections ofNew Notes.

• Address issues related to the payment of the Indenture Trustee fees under thePlan.

• Review and internally confer regarding the motion of Dr. Seymour Licht tocompel disclosure of the results of creditors' elections of New Notes and/or NewCommon Stock (the "Licht Motion").

• Draft Debtors' response to the Licht Motion.

• Prepare for, attend, and argue at the hearing to consider the Licht Motion.

• Prepare emergence checklist and attend to any outstanding emergence issues,including revise certain emergence documents.

• Draft, review, and revise rescission and settlement agreements (the "RescissionAgreements"), entered into by the Debtors with MatlinPatterson GlobalOpportunities Partners L.P., MatlinPatterson Global Opportunities Partners(Bermuda) L.P. and MatlinPatterson Phoenix SPY L.L.c. (collectively, the"MatlinPatterson Group") and NBT PS Partners LLC and its subsidiary DeerValley (Delaware) LLC (collectively, "Silver Lake").

HOI :\297666\01\6D_$01!.DOC\8!793.0004 48

• Draft motion seeking approval of the Rescission Agreements, which void andterminate certain letter agreements entered into by the Debtors on December 23,2003 with the MatlinPatterson Group and December 26,2003 with Silver Lake(as amended and superseded on January 26,2004, the "Letter Agreements").

bb.Exit Financing (Work Code W570)


188.5$80,536.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Michael Merola, Andrew Yoon and Jeremy Goldman. Their timerepresents 96% of the time billed to this work code.

• Assist the Debtors in negotiating, reviewing and executing exit financingdocuments, including (i) Letter of Credit Reimbursement Agreements withJPMorgan Chase Bank, Citibank, N.A. and Bank of America, N.A. and (ii) CashCollateral Agreements with JPMorgan Chase Bank, Citibank, N.A. and Bank ofAmerica, N.A.

• Attend to issues related to subsidiary guarantors of the Debtors.

• Revise the New Notes Indenture.

cc. MCI/Allegiance (Work Code W650)


326.6$103,711.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Alfredo Perez, James Grogan and Sharon Loftspring. Their timerepresents 71% of the time billed to this work code.

• In connection with the provision of utility services by the Debtors to AllegianceTelecom, Inc. ("Allegiance Telecom"), a facilities based CLEC with a nationwidenetwork and a facility based business strategy, continuously monitor and reviewthe chapter 11 case docket of debtor Allegiance Telecom.

• Negotiate and draft stipulated order for termination of Allegiance Telecom's useof a facility in Beltsville, Maryland.

• Prepare proofs of claim against Allegiance Telecom's chapter 11 estates.

• Draft motion to lift the automatic stay against Allegiance Telecom.

• Prepare for, attend and argue at hearing to consider the motion to lift theautomatic stay against Allegiance Telecom.

HOI :\297666\01\60_$01 !.DOC\81793.0004 49

• Review and apprise client of various pleadings in the Allegiance Telecom case,including Allegiance Telecom's proposed disclosure statement and plan ofreorganization, and the proposed sale of stock in Allegiance Telecom to XOCommunications, Inc.

• Draft objections on behalf of MCI to Allegiance Telecom's proposed plan anddisclosure statement.

• Argue in support of MCl's objections to Allegiance Telecom's proposed plan anddisclosure statement objections at hearings on same.

• Participate in discovery related to confirmation of Allegiance Telecom's proposedplan of reorganization.

• Negotiate and draft settlement with Allegiance Telecom related to proofs of claimand plan objection.

dd.Appeals (Work Code W670)


38.9$15,214.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Alfredo Perez and Lydia Protopapas. Their time represents 69%of the time billed to this work code.

• In connection with the settlement agreement (the "SEC Settlement") with the SECregarding the SEC's causes of action against the Debtors for alleged violations ofsections lO(b), 13(a) and 17(a) of the Securities Exchange Act of 1934 (the "SECAction"), which was pending in the United States District Court for the SouthernDistrict of New York (the "District Court"), attend to issues related to the appealsof the SEC Settlement commenced by HSBC Bank, USA ("HSBC"), thedissenting MCI Bondholders and the Ad Hoc Trade Claims Committee.

• Review the SEC Settlement in connection with the above-mentioned appeals.

• Negotiate, draft and revise the stipulations to stay the appeals of the SECSettlement with HSBC, the dissenting MCI Bondholders and the Ad Hoc TradeClaims Committee.

HOl:\297666\OI\6D_$Ol LDOC\81793.0004 50

ee. Nucentrix (Work Code W680)


77.1$31,692.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Stefan Wright and James Grogan. Their time represents 98% ofthe time billed to this work code.

• Participate in negotiations of assumption and assignment of Nucentrix BasicTrading Area ("BTA") agreement to Nextel Communications, Inc (the "BTAAgreement").

• Draft the BTA Agreement.

• Draft emergency motion for an order approving the assumption and assignment ofBTA lease and option agreement with Nucentrix Broadband Networks, Inc.

• Draft the declaration for an expedited hearing to consider theaforementioned motion.

• Prepare for, attend and argue at the hearing to consider the motion.

ff. ATN (Work Code W690)


325.0$114,436.00

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Jason Billeck and Christopher Lopez. Their time represents 80%of the time billed to this work code.

• Draft objection to the amended claim for administrative expense claims filed byAdvanced Telecommunication Network, Inc., ("ATN").

• Draft papers to convert ATN's claim for administrative expense claims into anadversary proceeding to join a responsible third party, Cypress Communications("Cypress").

• Research regarding ATN's claims and the Debtors' claims against ATN andCypress.

• Draft adversary complaint against ATN and Cypress.

• Negotiate the scope and deadlines for discovery with ATN and prepare for andparticipate in hearing with the Court regarding the discovery disputes with ATN.

HOI :\297666\01 \60_$01 !.DOC\81793.0004 51

• Respond to ATN's requests for interrogatories, document production, anddeposition notices.

• Draft interrogatories, requests for production, and deposition notices on behalf ofthe Debtors.

• Negotiate and draft a confidentiality agreement between the Debtors, ATN, andCypress regarding discovery.

• Review documents for production to ATN and documents produced by ATN andCypress.

• Negotiate potential settlement options with ATN and Cypress.

• Research regarding status and filings in ATN's chapter 11 case.

• Negotiate and draft scheduling order of the ATN/Cypress adversary proceeding.

• Review ATN's and Cypress's counterclaims against the Debtors and work onanswers to each.

gg. Examiner Investigation (Work Code W700)


316.3$160,599.50

The primary billing attorneys that provided services under this work code during the FourthCompensation Period were Marcia Goldstein, Adam Strochak, Kristin King and RonitBerkovich. Their time represents 91% of the time billed to this work code.

• In connection with the investigation of Dick Thornburgh, the Bankruptcy CourtExaminer, of certain prepetition tax minimization strategies recommended byKPMG LLP and implemented by the Debtors:

• Participate in preparing witnesses for interviews in connection with theExaminer's investigation:;

• Attend the interview of such witnesses;

• Participate in numerous discussions with the Examiner regarding theinvestigation and the Debtors' position with respect to the investigation.

• Review the Examiner's Third and Final Report, dated January 26,2004.

HOI:\297666\0l\6D_$OI LDOC\81793,OOO4 52

hh.PT Cable (Pacific Telecom) (Work Code W710)


0.1$36.50

The primary billing attorney that provided services under this work code during the FourthCompensation Period was James Grogan. His time represents 100% of the time billed to thiswork code.

REASONABLE AND NECESSARY SERVICES RENDEREDBY WG&M DURING THE FOURTH COMPENSATION PERIOD

42. The professional services performed by WG&M were necessary and

appropriate to the administration of the Reorganized Debtors' chapter 11 cases and were in the

best interests of the Reorganized Debtors and other parties in interest. Compensation for the

services described above is commensurate with the complexity, importance, and nature of the

problems, issues, or tasks involved.

43. A significant amount of the services performed by members and associates

of WG&M were rendered by the BFR Department. WG&M has a preeminent practice in this

area and enjoys a national reputation for its expertise in financial reorganizations and

restructurings of troubled entities, with approximately 80 attorneys (in the New York office

alone) that specialize in this area of law.

44. The professional services performed by WG&M on behalf of the Debtors

during the Fourth Compensation Period required an aggregate expenditure of 26,160.4 recorded

hours by WG&M' s members, counsel, associates, and paraprofessionals. Of the aggregate time

expended, 7,294.1 recorded hours were expended by partners and counsel ofWG&M, 14,516.0

recorded hours were expended by associates, and 4,350.3 recorded hours were expended by

paraprofessionals of WG&M. The professional services were performed with expedience and in

an efficient manner.

HOI :\297666\01 \60_$01 !.DOC\81793.0004 53

45. During the Fourth Compensation Period, WG&M's hourly billing rates for

attorneys ranged from $250 to $775 per hour. Allowance of compensation in the amount

requested would result in a blended hourly billing rate of approximately $404.13 (based on

26,160.40 recorded hours at WG&M's regular billing rates in effect at the time of the

performance of services [or approximately $457.81 per hour if you exclude paraprofessional

time)]. Such fees are reasonable based on the customary compensation charged by comparably

skilled practitioners in comparable bankruptcy cases in a competitive national legal market. As

noted, attached hereto as Exhibit B is a schedule listing each WG&M professional and

paraprofessional who performed services in these cases during the Fourth Compensation Period,

the hourly rate charged by WG&M for services performed by each such individual, and the

aggregate number of hours and charges by each such individual.

ACTUAL AND NECESSARY DISBURSEMENTS OFWG&M DURING THE FOURTH COMPENSATION PERIOD

46. As set forth in Exhibit C hereto, WG&M has disbursed $661,628.34 as

expenses incurred in providing professional services during the Fourth Compensation Period.

These expenses are reasonable and necessary in light of the size and complexity of the Debtors'

cases. In addition, numerous critical and unique issues have arisen in connection with these

cases. Therefore, in order for WG&M to properly analyze and address such issues, WG&M

attorneys have performed considerable research, all of which was necessary to further the

Debtors' reorganization and was in the best interests of the Debtors' estates.

47. The time constraints facing the Debtors, along with the sheer magnitude of

tasks generated by these cases, have required WG&M's attorneys and other employees to devote

significant time during the evenings and on weekends to perform legal services on behalf of the

Debtors. Such services were essential to meet deadlines, timely respond to motions and

HOI :\297666\01\6D_$01 LDOC\81793.0004 54

objections, and to satisfy the extraordinary demands of the Debtors' businesses and the

administration of these complex chapter 11 cases.

48. While WG&M does not generally charge the Reorganized Debtors for any

overtime expenses, consistent with firm policy, attorneys and other employees of WG&M who

worked late into the evenings or on weekends were reimbursed for their reasonable meal costs

and their cost for transportation from the office to home. WG&M's regular practice is not to

include components for those charges in overhead when establishing billing rates and to charge

its clients for these and all other out-of-pocket disbursements incurred during the regular course

of the rendition of services. The reimbursement amounts do not exceed those set forth in the

Guidelines.

49. With respect to photocopying expenses, WG&M charges its clients $.20

per page. With respect to facsimile expenses, WG&M charges $1.00 per page for outgoing

facsimile transmissions. In addition, the actual cost of any long distance charges are separately

itemized. This combined rate is invariably less than $1.25 per page, the amount permitted by the

Guidelines. Each of these categories of expenses does not exceed the maximum rate set by the

Guidelines. These charges are intended to cover WG&M's direct operating costs, which costs

are not incorporated into the WG&M hourly billing rates. Only clients who actually use services

of the types set forth in Exhibit C are separately charged for such services. The effect of

including such expenses as part of the hourly billing rates would impose that cost upon clients

who do not require extensive photocopying and other facilities and services. The amount of the

standard photocopying charge is intended to allow WG&M to cover the related expenses of

its photocopying service. A determination of the actual expenses per page for photocopying,

HOl:\297666\Ol\6D_$OI !.DOC\81793.0004 55

however, is dependent on both the volume of copies and the total expenses attributable to

photocopying on an annual basis.

50. In addition, because of the location of the Reorganized Debtors'

businesses in relation to WG&M's offices, frequent long distance telephone calls were required.

On several occasions, overnight delivery of documents and other materials was required as a

result of circumstances necessitating the use of such express services. These disbursements are

not included in WG&M's overhead for the purpose of setting billing rates. WG&M has made

every effort to minimize its disbursements in these cases. The actual expenses incurred in

providing professional services were necessary, reasonable, and justified under the circumstances

to serve the needs of the Debtors, their estates, and creditors.

FINAL COMPENSATION REQUESTED BY WG&M

51. By this Application, WG&M also requests final allowance of

$39,754,184.17 for the Total Compensation Period, representing $37,132,504.16 as

compensation for professional services rendered and $2,621,680.01 as reimbursement for actual

and necessary expenses incurred by WG&M. In accordance with WG&M's prior Monthly Fee

Statements and interim fee applications in these chapter 11 cases, WG&M has received

$30,578,479.37 for fees and disbursements incurred from July 21,2002 through April 19, 2004.

The Holdback, which represents the total amount of holdbacks from prior compensation periods,

totaling $3,250,699.62, remains due and payable by the Reorganized Debtors to WG&M.

Additionally, $5,925,005.15, comprised of professional fees and disbursements for the Fourth

Compensation Period, remain outstanding. Since the Commencement Date, WG&M has

voluntarily written off fees totaling $180,800.81 and expenses totaling $20,070.07, for an

aggregate amount of $200,870.88.

HOI :1297666\01 \6D_$01!.DOC\81793.0004 56

52. The detailed time records and fee applications describing the professional

services rendered and itemizing the related expenses incurred throughout theses chapter 11 cases

prior to the Fourth Compensation Period have been previously filed with the Court and are

incorporated herein by reference, but not reiterated so as not to burden the Court with

unnecessary duplicative material.

53. During the pendency of these chapter 11 cases, an extraordinary amount of

professional services were required, under severe time constraints, to deal with various critical

issues faced by the Debtors. Throughout these cases, WG&M prepared and filed, on behalf of

the Debtors many documents, including motions, briefs, and responsive pleadings. WG&M

advised and assisted the Debtors throughout these chapter 11 cases, and has staffed these cases

with a core group of professionals to ensure efficiency and to minimize costs. Where needed,

WG&M drew upon additional attorneys from other departments to provide specific expertise,

e.g., for the litigation involved in the sale of Embratel. WG&M believes it assisted the

Reorganized Debtors in an efficient and cost-effective manner and that its assistance achieved

outstanding result - the emergence of the Reorganized Debtors from the largest bankruptcy ever

filed. Under the circumstances, its request for final approval of professional fees and

reimbursement of expenses should be approved as requested.

THE REQUESTED COMPENSATION SHOULD BE ALLOWED

54. Section 331 of the Bankruptcy Code provides for interim compensation of

professionals and incorporates the substantive standards of section 330 to govern the Court's

award of such compensation. 11 U.S.c. § 331. Section 330 provides that a court may award a

professional employed under section 327 of the Bankruptcy Code "reasonable compensation for

actual necessary services rendered ... and reimbursement for actual, necessary expenses." Id.

HOI :\297666\01\6D_$01 LDOC\81793.0004 57

§ 330(a)(I). Section 330 also sets forth the criteria for the award of such compensation and

reimbursement:

In determining the amount of reasonable compensation to beawarded, the court should consider the nature, the extent, and thevalue of such services, taking into account all relevant factors,including --

(A) the time spent on such services;

(B) the rates charged for such services;

(C) whether the services were necessary to theadministration of, or beneficial at the time at which theservice was rendered toward the completion of, a caseunder this title;

(D) whether the services were performed within areasonable amount of time commensurate with thecomplexity, importance, and nature of the problem, issue,or task addressed; and

(E) whether the compensation is reasonable based onthe customary compensation charged by comparably skilledpractitioners in cases other than cases under this title.

Id. § 330(a)(3).

55. In the instant case, WG&M respectfully submits that the services for

which it seeks compensation in this Application were necessary for and beneficial to the

Reorganized Debtors' rehabilitation and reorganization efforts. Such services and expenditures

were necessary to and in the best interests of the Debtors' estates. In light of the nature, extent,

and value of such services to the Debtors, their estates, and all parties in interest, and because of

the magnitude and complexity of the Debtors' chapter 11 cases, the compensation requested

herein is reasonable.

56. The services rendered by WG&M were necessary and beneficial to the

Debtors' estates, and were consistently performed in a timely manner commensurate with the

HOl:\297666\01l6D_$OI !.DOC\81793.0004 58

complexity, importance, and nature of the issues involved. Accordingly, approval of the

compensation sought herein is warranted.

57. Pursuant to Local Bankruptcy Rule for the Southern District of New York

9013-1(b), because there are no novel issues of law presented herein, the Debtors respectfully

request that the Court waive the requirement that the Reorganized Debtors file a memorandum of

law in support of this motion.

58. No previous motion for the relief sought herein has been made to this or

any other court.

WHEREFORE WG&M respectfully requests (i) final allowance and payment of

compensation for professional services rendered during the Fourth Compensation Period in the

amount of $10,572,220.19 and reimbursement for actual and necessary expenses WG&M

incurred during the Fourth Compensation Period in the amount of $661,628.34 (less amounts

previously paid to WG&M), (ii) final allowance of compensation for professional services

rendered during the Total Compensation Period in the amount of $37,132,504.16, and

reimbursement for actual and necessary expenses incurred during the Total Compensation Period

in the amount of $2,621,680.01 (which amounts include the fees and expenses requested for the

-REMAINDER OF PAGE INTENTIONALLY LEFT BLANK-

HOI :\297666\01\6D_$01 LDOC\81793.0004 59

Fourth Compensation Period and the Holdback), (iii) that this Court direct and authorize the

Reorganized Debtors as of the date an order approving this Application is approved to pay

\VG&M the amounts outstanding, totaling $6,144,538.37 (which was reduced by the Retainer

and Credit held by WG&M) that WG&M has not yet received from the Debtors for the Total

Compensation Period, and (iv) that this Court grant WG&M such other and further relief as is

just.

Dated: Houston, TexasJuly 19,2004

HOI :1297666\01\60_$01 LOOC\81793.0004

Marci . Goldstein, Esq. G 2606)Lori R. Fife, Esq. (LF 2839)

WElL, GOTSHAL & MANGES LLP767 Fifth AvenueNew York, NY 10153-0119Telephone: (212) 310-8000Facsimile: (212) 310-8007

and

Alfredo R. Perez, Esq.

WElL, GOTSHAL & MANGES LLP700 Louisiana, Suite 1600Houston, TX 77002Telephone: (713) 546-5000Facsimile: (713) 224-9511

Attorneys for the Reorganized Debtors

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